Williamson v. Mazda Motor of America, Inc.
562 U.S. 323
SCOTUS2011Background
- FMVSS 208 (1989) allows rear inner seats to use either lap belts or lap-and-shoulder belts, while rear outer seats require lap-and-shoulder belts.
- Williamson family sues Mazda in California, alleging Mazda should have installed lap-and-shoulder belts on rear aisle seats after Thanh Williamson died wearing a lap belt.
- Lower courts dismissed the tort claim as pleading-stage and affirmed on appeal.
- Geier v. American Honda Motor Co. held that FMVSS 208 allowed manufacturer choice and could pre-empt a state suit forcing a specific device (airbags).
- Petition granted to decide whether the Williamsons' tort claim pre-empts under FMVSS 208, given it would restrict belt-choice.
- Court held that the regulation does not pre-empt the tort action because belt-choice on rear inner seats was not a significant regulatory objective.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Does FMVSS 208 pre-empt the Williamsons' state tort claim? | Williamsons: pre-emption because suit would force a particular belt option, obstructing federal objective. | Maz da: save clause prevents pre-emption; common-law actions fall outside express clause and cannot override safety standard. | No; no obstacle to federal objectives means no pre-emption. |
| Does the saving clause foreclose ordinary conflict preemption? | Geier contemplated saving clause does not foreclose ordinary pre-emption. | Maintains saving clause preserves state tort law and bars pre-emption. | Saving clause does not foreclose ordinary conflict preemption here; case resolves on textual grounds. |
| Is there an obstacle-to-objectives pre-emption under ordinary conflict preemption? | Agency history shows objective to maintain choice; tort suit undermines that objective. | Agency history does not show choice was a significant regulatory objective to justify pre-emption. | No; the regulation does not stand as an obstacle to full federal objectives. |
Key Cases Cited
- Geier v. American Honda Motor Co., 529 U.S. 861 (U.S. 2000) (saving clause does not bar ordinary conflict preemption; regulation may pre-empt tort suits if obstacle to objectives)
- Hillsborough County v. Automated Medical Laboratories, Inc., 471 U.S. 707 (U.S. 1985) (state laws can be pre-empted by federal regulations)
- Medtronic, Inc. v. Lohr, 518 U.S. 470 (U.S. 1996) (tort law interplay with federal standards; common-law duties may be pre-empted)
- Cipollone v. Liggett Group, Inc., 505 U.S. 504 (U.S. 1992) (conflict preemption principles apply to federal standards and state law)
- Wyeth v. Levine, 555 U.S. 555 (U.S. 2009) (discusses saving clause and pre-emption limits; emphasizes textual approach)